Osflo Fertiliser Ltd consent compliance monitoring report - Taranaki ...

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The Osflo Fertiliser Ltd (Osflo) operate a facility for storage, blending and distribution of poultry waste fertiliser.
Osflo Fertiliser Ltd Monitoring Programme Annual Report 2016-2017 Technical Report 2017-65

Taranaki Regional Council ISSN: 1178-1467 (Online)

Private Bag 713

Document: 1888872 (Word)

STRATFORD

Document: 1903234 (Pdf)

August 2017

Executive summary The Osflo Fertiliser Ltd (Osflo) operate a facility for storage, blending and distribution of poultry waste fertiliser. The site is located on Hursthouse Road, Lepperton, in the Wainogana catchment. This report for the period July 2016 to June 2017 describes the monitoring programme implemented by the Taranaki Regional Council (the Council) to assess Osflo’s environmental and consent compliance performance during the period under review. The report also details the results of the monitoring undertaken and assesses the environmental effects of their activities. Osflo hold two resource consents, these include a total of 18 conditions setting out the requirements that Osflo must satisfy. Osflo holds one consent to allow it to discharge stormwater and treated waste water from the poultry litter storage area into land in the vicinity of the Awai Stream, and one consent to discharge emissions into the air from the use and storage of the used chicken litter. This report represents the twenty third report on the environmental performance of Osflo. During the monitoring period, Osflo demonstrated an overall Good level of environmental performance. The Council’s monitoring programme for the year under review included four site inspections, which include odour surveys, and eight water samples collected for physicochemical analysis. In addition, the Council was also required to undertake eight additional inspections with respect to complaints from the public, specifically related to odour. On one of these occasions the investigating officer identified a constant objectionable odour from the premises which resulted in the issuance of an abatement notice. In comparison to last year’s monitoring report, where only one odour complaint was received with regard to the company’s processes. This year drew significantly more complaints in comparison. Following on from the issuance of the abatement notice, the site management reacted in a proactive manner and purchased additional engineering controls to mitigate the issue. At the same time, the management undertook excavation of older concrete material from the base of the mixing pad, whereby they uncovered an aged water pipe which was proposed to have been leaking for some time. This water leak was inferred to be a contributor to the source of odour, as washings from the yard had likely infiltrated and interacted with the leaking pipe beneath the pad and plausibly turned anoxic which could have resulted in excessive odour production. Stream water sampling of the Awai Stream was undertaken this year. This marked the second consecutive year with respect to this analysis, and in comparison to the previous monitoring year, actual effects were less than minor. Short term odour impacts are the main environmental effect associated with the exercise of this consent and the Council will continue to assess this facility moving forward. Site development plans have slipped when compared to the original staged and dated approach, however a firm commitment has been given by the site management to maintain the final time line date of 1 June 2019. During the year, Osflo demonstrated a high level of environmental and administrative performance with respect to discharge consent 4333-3 (Discharge of treated waste and stormwater to ground through soakage) the resource consents. During the year, Osflo demonstrated a needs improvement level for environmental performance and a good level for administrative performance with respect to air discharge consent 5918-2.

For reference, in the 2016-2017 year, consent holders were found to achieve a high level of environmental performance and compliance for 74% of the consents monitored through the Taranaki tailored monitoring programmes, while for another 21% of the consents, a good level of environmental performance and compliance was achieved. In terms of overall environmental and compliance performance by the consent holder over the last several years, this report shows that the consent holder’s performance has been lower than in previous years.

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Table of contents Page Introduction

1 1.1

1.2

1.3

1.4

2

Compliance monitoring programme reports and the Resource Management Act 1991

1

1.1.1

Introduction

1

1.1.2

Structure of this report

1

1.1.3

The Resource Management Act 1991 and monitoring

1

1.1.4

Evaluation of environmental and administrative performance

2

Process description

4

1.2.1

Odour mitigation

5

1.2.2

Site Improvements

6

Resource consents

7

1.3.1

Water discharge permit

7

1.3.2

Air discharge permit

7

1.3.3

Discharges of wastes to land

8

Monitoring programme

8

1.4.1

Introduction

8

1.4.2

Programme liaison and management

8

1.4.3

Site inspections

8

1.4.4

Chemical sampling

9

Results

10

2.1

Inspections

10

2.2

Results of receiving environment monitoring

12

2.2.1

Awai Stream sampling

12

2.2.2

Results

14

2.3

Other ambient monitoring

15

2.4

Investigations, interventions, and incidents

15

3

4

1

Discussion of site performance

20

3.1

Environmental effects of exercise of consents

20

3.2

Evaluation of performance

21

3.3

Recommendations from the 2015-2016 Annual Report

23

3.4

Alterations to monitoring programmes for 2017-2018

23

Recommendations

Glossary of common terms and abbreviations

24 25

ii

Bibliography and references

27

Appendix I Resource consents held by Osflo Fertiliser Ltd

List of tables Table 1

Surface water sampling Awai Stream Osflo 2016-2017 monitoring period

14

Table 2

Parameter index

15

Table 3

Summary of performance for consent 4333-3 (2016-2017)

21

Table 4

Summary of performance for consent 5918-2 (2016-2017)

22

Table 5

Evaluation of environmental performance over time

22

List of figures Figure 1

Osflo site on the Hursthouse Road

4

Figure 2

Staging of site development

6

Figure 3

Aerial view of Osflo site with associated sample collection points

13

Figure 4

Osflo soakage pond setup

13

List of photos Photo 1

Osflo yard cleaning machinery

18

Photo 2

Osflo blending pad staff member moving excess material to the storage shed with blower

19

Photo 3

Osflo odourisers

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1

1

Introduction

1.1

Compliance monitoring programme reports and the Resource Management Act 1991

1.1.1 Introduction This report is for the period July 2016 to June 2017 by the Taranaki Regional Council (the Council) on the monitoring programme associated with resource consents held by Osflo Fertiliser Ltd (Osflo). Osflo operate a used chicken litter storage and distribution facility located on Hursthouse Road, Lepperton, in the Waiongana Catchment. This report covers the results and findings of the monitoring programme implemented by the Council in respect of the consents held by Osflo that relate to discharge of stormwater within the Waiongana Catchment, and the air discharge permit held by Osflo to cover emissions to air from the site. One of the intents of the Resource Management Act 1991 (RMA) is that environmental management should be integrated across all media, so that a consent holder’s use of water, air, and land should be considered from a single comprehensive environmental perspective. Accordingly, the Council generally implements integrated environmental monitoring programmes and reports the results of the programmes jointly. This report discusses the environmental effects of the Company’s use of water, land and air, and is the twenty third annual report by the Council for Osflo.

1.1.2 Structure of this report Section 1 of this report is a background section. It sets out general information about: 

consent compliance monitoring under the RMA and the Council’s obligations;



the Council’s approach to monitoring sites though annual programmes;



the resource consents held by the Company in the Waiongana catchment;



the nature of the monitoring programme in place for the period under review; and



a description of the activities and operations conducted in Osflo’s site/catchment.

Section 2 presents the results of monitoring during the period under review, including scientific and technical data. Section 3 discusses the results, their interpretations, and their significance for the environment. Section 4 presents recommendations to be implemented in the 2017-2018 monitoring year. A glossary of common abbreviations and scientific terms, and a bibliography, are presented at the end of the report.

1.1.3 The Resource Management Act 1991 and monitoring The RMA primarily addresses environmental ‘effects’ which are defined as positive or adverse, temporary or permanent, past, present or future, or cumulative. Effects may arise in relation to: a. the neighbourhood or the wider community around an activity, and may include cultural and socialeconomic effects; b. physical effects on the locality, including landscape, amenity and visual effects; c. ecosystems, including effects on plants, animals, or habitats, whether aquatic or terrestrial;

2 d. natural and physical resources having special significance (for example recreational, cultural, or aesthetic); and e. risks to the neighbourhood or environment. In drafting and reviewing conditions on discharge permits, and in implementing monitoring programmes, the Council is recognising the comprehensive meaning of ‘effects’ inasmuch as is appropriate for each activity. Monitoring programmes are not only based on existing permit conditions, but also on the obligations of the RMA to assess the effects of the exercise of consents. In accordance with Section 35 of the RMA, the Council undertakes compliance monitoring for consents and rules in regional plans, and maintains an overview of the performance of resource users and consent holders. Compliance monitoring, including both activity and impact monitoring, enables the Council to continually re-evaluate its approach and that of consent holders to resource management and, ultimately, through the refinement of methods and considered responsible resource utilisation, to move closer to achieving sustainable development of the region’s resources.

1.1.4 Evaluation of environmental and administrative performance Besides discussing the various details of the performance and extent of compliance by Osflo, this report also assigns them a rating for their environmental and administrative performance during the period under review. Environmental performance is concerned with actual or likely effects on the receiving environment from the activities during the monitoring year. Administrative performance is concerned with Osflo’s approach to demonstrating consent compliance in site operations and management including the timely provision of information to Council (such as contingency plans and water take data) in accordance with consent conditions. Events that were beyond the control of the consent holder and unforeseeable (that is a defence under the provisions of the RMA can be established) may be excluded with regard to the performance rating applied. For example loss of data due to a flood destroying deployed field equipment. The categories used by the Council for this monitoring period, and their interpretation, are as follows:

Environmental Performance High: No or inconsequential (short-term duration, less than minor in severity) breaches of consent or regional plan parameters resulting from the activity; no adverse effects of significance noted or likely in the receiving environment. The Council did not record any verified unauthorised incidents involving significant environmental impacts and was not obliged to issue any abatement notices or infringement notices in relation to such impacts. Good: Likely or actual adverse effects of activities on the receiving environment were negligible or minor at most. There were some such issues noted during monitoring, from self reports, or in response to unauthorised incident reports, but these items were not critical, and follow-up inspections showed they have been dealt with. These minor issues were resolved positively, co-operatively, and quickly. The Council was not obliged to issue any abatement notices or infringement notices in relation to the minor non-compliant effects; however abatement notices may have been issued to mitigate an identified potential for an environmental effect to occur. For example: -

High suspended solid values recorded in discharge samples, however the discharge was to land or to receiving waters that were in high flow at the time;

-

Strong odour beyond boundary but no residential properties or other recipient nearby.

3 Improvement required: Likely or actual adverse effects of activities on the receiving environment were more than minor, but not substantial. There were some issues noted during monitoring, from self reports, or in response to unauthorised incident reports. Cumulative adverse effects of a persistent minor non-compliant activity could elevate a minor issue to this level. Abatement notices and infringement notices may have been issued in respect of effects. Poor: Likely or actual adverse effects of activities on the receiving environment were significant. There were some items noted during monitoring, from self reports, or in response to unauthorised incident reports. Cumulative adverse effects of a persistent moderate non-compliant activity could elevate an ‘improvement required’ issue to this level. Typically there were grounds for either a prosecution or an infringement notice in respect of effects.

Administrative performance High: The administrative requirements of the resource consents were met, or any failure to do this had trivial consequences and were addressed promptly and co-operatively. Good: Perhaps some administrative requirements of the resource consents were not met at a particular time, however this was addressed without repeated interventions from the Council staff. Alternatively adequate reason was provided for matters such as the no or late provision of information, interpretation of ‘best practical option’ for avoiding potential effects, etc. Improvement required: Repeated interventions to meet the administrative requirements of the resource consents were made by Council staff. These matters took some time to resolve, or remained unresolved at the end of the period under review. The Council may have issued an abatement notice to attain compliance. Poor: Material failings to meet the administrative requirements of the resource consents. Significant intervention by the Council was required. Typically there were grounds for an infringement notice. For reference, in the 2016-2017 year, consent holders were found to achieve a high level of environmental performance and compliance for 74% of the consents monitored through the Taranaki tailored monitoring programmes, while for another 21% of the consents, a good level of environmental performance and compliance was achieved.

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1.2

Process description

Osflo operates a storage, blending and distribution facility for agricultural fertiliser based on poultry litter at the site of the old Tarurutangi dairy factory on Hursthouse Road, near Lepperton (Figure 1). The poultry waste is collected from farms around the Taranaki region, and sold as a registered fertiliser to be spread on pasture. The depot is the administration centre for collection and distribution of the used litter, with the majority of the product being taken directly from the poultry farm to the general farming customer. Some blending in of additional ingredients occurs at the depot. A total of 17 persons are employed in the operation, utilising seven trucks.

Figure 1 Osflo site on the Hursthouse Road Litter is stored at the depot when conditions are unsuitable for spreading on land, and to accumulate a reserve for periods of peak demand. Additives, such as lime, sulphur, chelated cobalt, and or selenium may be blended into the litter according to customer requirements, and are stored in a separate building. Up to about 35,000 tonnes per annum of litter is generated on farms within the Inglewood/Okato/Waitara area, mostly near Lepperton and Bell Block. This amount is forecast to increase owing to expansion of the poultry industry. The amount stored at the depot ranges from about 100 to 3,000 tonnes. Peak seasonal activity is in spring, for cropping, and in autumn, for dairy farming. The Hursthouse Road depot is on an area of about one hectare in the bottom of a valley, bounded on the north and west by the Awai Stream, on the east by Hursthouse Road, and on the south by a fence and tree shelter belt. The site is surrounded by farm grazing land, with four dwellings nearby beyond the site boundary, one 100 metres to the east, two within 300 metres to the southeast, and a new dwelling 250 metres to the south on a hill. The predominant winds in the area are westerly and south-easterly. The litter comprises poultry manure and wood shavings. Upon storage the litter undergoes decomposition by microbial organisms, a natural process which generates gases and heat. The majority of the gas is carbon dioxide and methane, which are odourless. Some odorous gases, both organic (aldehydes, ketones, organic acids, amines and organic sulphur compounds) and inorganic (ammonia, nitrogen oxides and hydrogen sulphide), are produced. The rate of heat generation depends on the amount of moisture and oxygen

5 available, and may lead to spontaneous combustion of the wood shavings and generation of smoke if not controlled. The storage shed is designed so that the fugitive emissions of gas from the storage of poultry wastes will not escape the building. Emissions are extracted by a fan and forced through a biofilter. Biofilters decompose odorous compounds, using micro-organisms such as bacteria. The use of an extraction fan within the closed facility has the added benefit of maintaining slight negative pressure inside the building, which reduces the egress of untreated gaseous emissions. The ventilation rate is increased during loading out, when the door is left open to allow clearer viewing by operators in the dusty conditions. An odourneutralising agent is pumped into the air from a manifold around the door while it is open. The store remains closed and inoperative for about 30% of days in the year. Filling takes place for about 50% of days in a year, and emptying for 20%. Additional components are mixed into the chicken litter, at present on the ground outside the store with a front-end loader (solids). Wastewater from washing down the trucks (with quaternary ammonia sanitiser) and yard, and stormwater from this area, is directed to a concrete settling pond which then overflows to two soakage pits in series that are situated beside the Awai Stream. A screen is placed between the holding pond and the first soakage pit to prevent solids from entering the pit. A third soakage pit was excavated in November 2014. Stormwater with less potential to be contaminated, from other areas of the premises, soaks to ground or is directed to the second soakage pit. Council compliance samples have focussed on assessing the quality of the Awai Stream as it passes the outside of the soakage area, via an upstream and downstream sample of the surface waters.

1.2.1 Odour mitigation Due to the nature of the facility, the potential for odour generation while undertaking blending and mixing operations on site is high. Thus, in order to limit the potential for odour generation the site follows a specific odour management plan. As well as the adherence to the odour risk management plan, the site has also undertaken various engineering controls to further mitigate the odour potential. These are as follows:

Odour neutralising spray Odour neutralising spray is used along the site boundary, just east of the storage shed. Its aim is to neutralise any potential odorous discharges emanating offsite. The odour neutralising spray system is in operation when trucks are loading and blending product. The frequency and volume of the spray can be adjusted to mitigate potential odour impact.

Road boundary hedge The south-eastern road boundary has been planted to help trap any potential odorous materials emanating offsite as well as screen site activities from neighbouring dwellings.

Bio-filter The bio-filter fan is set at minimum power setting during normal operation and set at maximum power when odour mitigation is required.

Store room doors Osflo are vigilant to make sure that the store doors will remain shut unless loading and unloading activities are occurring.

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1.2.2 Site Improvements It is Osflo’s intention to move all blending/mixing and loading/unloading activities indoors by 2019; this was originally proposed in four stages, however, Stage 3 and Stage 4 are now to be combined. These stages are now as follows: Stage 1 activities include:   

land acquisition to the west of the site adjoining the Hursthouse Road reserve; landscaping the portion adjoining the road reserve for visual amenity and odour buffer purposes; and the use of neutralising odour spray at the boundaries, as an interim solution for the minimisation of odour effects beyond the boundaries.

Stage 2 activities include:  

the construction of a new workshop; and the upgrade of the existing wastewater treatment system.

Stage 3, now combined with Stage 4, and involves the demolition of the existing storage/workshop shed and the renovation/extension of the existing storage facility to accommodate mixing, loading and unloading activities. At the time that this report was composited 24 months had past since the consent 5918-2 was granted. Osflo has undertaken Task 1, though no demolition work had been actioned for Stage 2. Additional plans have been discussed with the Council and Osflo intend to continue with the consented progress, and accept that they have not met their commitment time line for development in terms of Stage 2. But they remain firm in there commitment to the final date of June 2019.

Figure 2

Staging of site development

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1.3

Resource consents

1.3.1 Water discharge permit Section 15(1)(a) of the RMA stipulates that no person may discharge any contaminant into water, unless the activity is expressly allowed for by a resource consent or a rule in a regional plan, or by national regulations. Osflo held one permit to discharge to water during the 2015-2016 review period, discharge permit 4333-3. Discharge permit 4333-3, to discharge treated wastewater and stormwater from poultry litter storage yard washings into land via soakage, in circumstances where it may enter ground and surface water, was issued by the Council on 30 June 2015 under Section 87(e) of the RMA. It is due to expire on 1 June 2026. There are 16 conditions attached to this permit.   

    

Condition 1 requires adoption of the best practicable option to prevent or minimise effects. Conditions 2 and 3 apply to discharge to water, before 1 June 2019, placing limits on significant potential contaminants beyond a mixing zone, and standards on the effluent itself. Conditions 4 to 10 apply to discharge to land, after 1 June 2019. 

Condition 4 prohibits direct discharge of wastewater to Awai Stream.



Conditions 5 to 7 relate to operation of the disposal system.



Conditions 8 to 10 relate to the design and construction of the disposal system.

Condition 11 limits the size of the washwater catchment. Condition 12 requires all stormwater to be treated. Conditions 13 and 14 require the production of spill contingency plan and a management plan. Condition 15 deals with changes in processes or operations, and Condition 16 provides for review of consent.

A copy of permit 4333-3 is attached to this report in Appendix I.

1.3.2 Air discharge permit Section 15(1)(c) of the RMA stipulates that no person may discharge any contaminant from any industrial or trade premises into air, unless the activity is expressly allowed for by a resource consent, a rule in a regional plan, or by national regulations. Osflo holds air discharge permit 5918-2 to discharge emissions into the air from the storage and distribution of used poultry litter fertiliser. This consent was issued by the Council on 30 June 2015 under Section 87(e) of the RMA. It is due to expire on 1 June 2026. There are eight conditions attached to this permit.        

Condition 1 requires adoption of the best practicable option to prevent or minimise effects. Condition 2 requires the containment of all potentially odorous material for treatment of emissions by 1 June 2019. Condition 3 prohibits offensive or objectionable odour beyond the site boundary. Condition 4 deals with change in process. Condition 5 require the door of the store to be kept shut except during entry and exit. Condition 6 addresses dust. Condition 7 requires the site to be operated in accordance with an approved odour management plan. Condition 8 is a review provision.

A copy of the permit 5918-2 is attached to this report in Appendix I.

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1.3.3 Discharges of wastes to land Sections 15(1)(b) and (d) of the RMA stipulate that no person may discharge any contaminant onto land if it may then enter water, or from any industrial or trade premises onto land under any circumstances, unless the activity is expressly allowed for by a resource consent, a rule in a regional plan, or by national regulations. Until 2009, Osflo held discharge permit 3923-1 to cover the placement of up to 12 tonnes per hectare of the Ministry of Agriculture and Fisheries-registered organic fertiliser onto land in the Taranaki region. This consent expired on 1 June 2009 and was not replaced, as, under Rule 31 of the Regional Freshwater Plan for Taranaki (RFWP), which had become operative in October 2001, the activity was now a permitted activity. Certificate of compliance 7463-0 was issued to Osflo, pursuant to Section 139 of the RMA, in respect of the discharge of fertiliser onto and into land at various locations throughout the Taranaki region, on 26 March 2009. The activity is permitted provided there is compliance with four conditions that are intended to avoid adverse effect on soil and water. A copy of the certificate with conditions is attached in Appendix I. There is no scheduled compliance monitoring associated with a permitted activity, though breach of any of the conditions may be the subject of enforcement action. These summaries of consent conditions may not reflect the full requirements of each condition. The consent condition sin full can be found in the resource consent, which is appended to this report.

1.4

Monitoring programme

1.4.1 Introduction Section 35 of the RMA sets obligations upon the Council to gather information, monitor and conduct research on the exercise of resource consents within the Taranaki region. The Council is also required to assess the effects arising from the exercising of these consents and report upon them. The Council may therefore make and record measurements of physical and chemical parameters, take samples for analysis, carry out surveys and inspections, conduct investigations and seek information from consent holders. The monitoring programme for the Osflo site consisted of three primary components.

1.4.2 Programme liaison and management There is generally a significant investment of time and resources by the Council in:     

ongoing liaison with resource consent holders over consent conditions and their interpretation and application; in discussion over monitoring requirements; preparation for any consent reviews, renewals or new consent applications; advice on the Council's environmental management strategies and content of regional plans; and consultation on associated matters.

1.4.3 Site inspections The Osflo site was visited on four occasions during the monitoring period. With regard to consent for the discharge, the main points of interest were plant processes with potential discharges to receiving watercourses, including contaminated stormwater and process wastewaters.

9 Air inspections focused on plant processes with associated actual and potential emission sources and characteristics, including potential odour, odour surveys, dust, noxious or offensive emissions. Sources of data being collected by the consent holder were identified and accessed if required, so that performance in respect of operation, internal monitoring, and supervision could be reviewed by the Council. The neighbourhood was surveyed for environmental effects. Further site inspections were also undertaken in response to complaints from the public.

1.4.4 Chemical sampling The Council undertook sampling of the water quality upstream and downstream of the soakage point and potential mixing zone on the Awai Stream on four separate occasions. The water samples were analysed for the following:        

Bio-chemical Oxygen demand 5 day Conductivity Dissolved reactive phosphorus Faecal coliforms Ammoniacal Nitrogen pH Temperature Turbidity

Originally discharge samples were proposed; however the site is non discharge location as the discharges now soak into a soakage pond. The aim of the upstream and downstream sampling is to ascertain whether the soakage pond and/or the facility may or may not be adversely affecting the Awai Stream in this locality.

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2

Results

2.1

Inspections

The following inspections relate to regular compliance monitoring inspection undertaken of Osflo’s facility on the Hursthouse Road. Additional inspections were also undertaken in response to complaints from the public. A list of additional inspections is provided in Section 2.3.

1 November 2016 At the time of inspection the wind was light and variable from the North at 3-4 m/s. An upwind odour assessment was undertaken at the entrance to the residence whereby no odour was noticeable. A downwind trajectory was assumed to be across the paddocks which do not contain dwellings. Quality of product received from the supplier has been cited as a potential for increased odorousness and Osflo are working with the supplier to correct this issue. This is dealt with on a batch basis. A site walkover was undertaken; the site appeared well kept, with good house keeping practices evident. A noticeable odour was detected when in close proximity to the soakage ponds, which were noted to have significant sediment accumulation. The cleaning of the ponds is scheduled in the routine site management. In the past this has been gifted as free fertiliser to neighbors if required. It constitutes the washings from the yard, post loading and blending. At the time of inspection the storage room doors were fully closed and the shed was assumed to be around twenty percent full. Site management remarked that they are in the midst of a busy period.. Mineral deposit load out areas appeared well managed. The odorisers were functional upon inspection. The bio-filter was observed and found to be functioning, with a bark type odour lightly permeating from the bio-filter as is normal for this device. The laydown area was observed, as was the line of cedars which have entered their second year. Recent complaints were discussed, in relation to odour and communication with the interested parties (as stated in there site specific odour risk management plan). Notifications will continue to be sent out in times of high odour generation potential. Water quality sampling was undertaken at the upstream and downstream sample locations, the Awai Stream was in low flow and appeared clear with low turbidity. A truck was loaded while the sampling was undertaken and no additional odour was noticed.

15 February 2017 At the time of the inspection the weather was fine, a light wind was blowing from the North, estimated to be 1-2 m/s, cloud cover 5/8. An upwind odour survey was undertaken, at the nearest receptor, and no odour was detected. No downwind survey was undertaken as there are minimal receptors in that specific wind direction. The Osflo site manager was present for the duration of the site inspection. The site was described as clean, well managed with little odour. The plant manager recently commissioned a piece of machinery tasked with keeping the yard clean. This was in operation at the time of inspection and seemed effective in removing surface litter from the mixing yard. The doors were open at the time of inspection as the staff were in the process of cleaning the yard and sweeping spilled material (of which there was little) into the mostly empty storage shed. The storage room doors were quickly closed once the yard cleaning had been undertaken. The soakage ponds were observed. The site manager remarked they are programmed to be cleaned out within the next month. The biofilter was observed and discussions were held about maintaining a log with respect to biofilter condition checks.

11 The mineral storage areas were observed and were found to be well managed. The odourisers were functioning at the time of the inspection. Discussions are being held with Egmont Air to further improve the efficiency of these devices. New posts have been installed at the front of the establishment, proposed diffusion breaks are in the process of being installed. Communication has been ongoing, with Osflo holding a running log of every time they have notified their neighbors with respect to conditions which have created the potential for odour generation. This is inline with their odour management plan. In terms of site developments, within the next month Osflo hopes to be able to produce a timeline of the newly proposed development, which will be in keeping with their consent. Water samples were collected at the downstream and upstream locations. The Awai Stream appeared to be in a low flow, and was described as clear with minimal turbidity observed.

19 April 2017 At the time of the inspection the weather was fine, partially cloudy (5/8th), warm with a very light, variable West to North West wind, of 1-2 m/s. An odour survey was undertaken at the residential entrances in close proximity to the site entrance. A very slight, non-continuous typical used chicken litter odour was occasionally detected, though very faint. The downwind odour assessment detected very light, continuous odours. The site manager accompanied the Council Officer for the inspection. There was minimal odour detected in the direct vicinity of the site office. The diesel and fuel storage areas were viewed and appeared to be in good order. The mixing area was observed and appeared well managed, with minimal odour. The site manager remarked that they are keeping the mixing area as clean as practicable. This included ensuring that all material is contained within the closed storage room door while not being loaded and that no material will be left outside, unless it is to be directly loaded. At the time of the inspection the huff was loading back into the store, the excess material which was not loaded on the previous truck. The door was then closed, with all internal odours sent to the bio-filter. The soakage ponds were observed and appeared to be functioning well, though a clean out will be required in due course. The bio-filter was observed and appeared in good order with minimal odour apparent. Site developments: the facility had undertaken some major excavations works in the past few months which removed a degree of older, weathered concrete material. This was replaced with new concrete, which was laid in close proximity to the storage shed and associated mineral storage areas. Additional tall posts had been erected at the entrance of the facility; these were to be fitted with shading cloth and associated odourisers in the coming months. The communication plan was discussed, whereby the site management stated that they have and maintain a good dialogue with their neighbors, whom they inform should the potential arise for odour generation and more recently noise generation in terms of the earth works which have been undertaken. Overall, the site appeared well managed and housekeeping was prevalent throughout. The odour, though noticeable at times, was at a low intensity for the duration of the inspection. Samples were collected of the Awai Stream, upstream and downstream.

8 June 2017 At the time of the inspection the following was observed. The weather was clear, bright with a light south east wind of 5 m/s. A downwind odour survey was undertaken whereby only light noticeable odours were detected though not objectionable. A covered Osflo truck drove past while undertaking the survey and little to no odour was apparent from the truck. The site manager accompanied the Council Officer for the duration of the inspection. The blending yard appeared to be well managed with good housekeeping

12 evident through out. It was noted though in some locations the concrete pad required additional patches and it was agreed that this will be programmed into the site maintenance schedule. Cleaning machinery was in the process of being serviced by on site staff. The storage room's doors were closed at the time of inspection. The storage shed was estimated to be 3/5 full of material. Strong chicken litter odours were contained within the storage room. However upon exiting and closing the facility door the odours relented which would imply the negative pressure was holding and drawing potential odours through to the bio-filter where they were treated. Soakage ponds were viewed and the main receiving pond had been recently cleaned out by staff. A recent finding of a ruptured water pipe which ran beneath the facility had been mitigated and as a result the observed odour in the blending area was notably lower than compared to previous visits. Odourises were in operation at the time of the inspection. Surface water samples were collected upstream and downstream of the facility, where the Awai stream appeared clear with no visual impacts from the consent holders operations. The management indicated that communication with the neighbors was ongoing.

2.2

Results of receiving environment monitoring

2.2.1 Awai Stream sampling This period marked the second year of site specific water quality monitoring programme with respect to the Awai Stream which flows around the Osflo facility; clockwise from the south and passing the facility to the north east (Figure 3). The main aim of the stream monitoring was to ascertain if the exercise of this consent resulted in any potential effects. Washings from the yard and from cleaning of the trucks are directed to the first soakage pond, which then goose necked through to a second and third pond when required (Figure 3). Sample locations AWY000223 and AWY000226 were set up as monitoring locations on the Awai Stream (Figure 4). AWY000223 is the upstream location, to determine the quality of the preceding stream conditions, whilst AWY000226 is the downstream location which will assess for any potential additional inputs to the stream as it flows around the Osflo facility.

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Figure 3 Aerial view of Osflo site with associated sample collection points

Figure 4 Osflo soakage pond setup

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2.2.2 Results In this monitoring period the Council collected, on four separate occasions, stream samples both upstream (AWY000223) and downstream (AWY000226) of the facilities’ associated soakage pond area (Figure 3). The analysis of these samples in provided in the following Table 1. The site does not discharge to the Awai Stream; rather it operates a soakage pond system (Figure 4). The aim of the surface water samples was to ascertain the quality of the preceding surface water quality and to compare it against the surface waters which have flowed past the soakage pond area. In this monitoring period, and in similarity to the previous monitoring period, the analysis of the surface waters indicated negligible impacts from the exercise of the consents. Condition 2 of Consent 4333-3, requires that the downstream sample location must meet specific criteria of analytes in terms of un-ionised ammonia and filtered carbonaceous biological oxygen deficit. The maximum concentration post discharge and mixing is limited to 0.025 g/m3 un-ionised ammonia and 2.0 g/m3 filtered carbonaceous BOD5 . When compared to the results in Table 1. The highest concentration of un-ionised ammonia was recorded on the 15 February 2017 at the downstream site at a concentration of 0.00069 g/m3 NH3. This concentration was well below the consented maximum. Filtered carbonaceous BOD concentrations were also similarly below the consented maximum, with seven of eight samples below the limit of reporting for this analyte. Dissolved reactive phosphorus concentrations ranged from